E-Rate Explained: What Every K-12 IT Director Needs to Know Right Now
E-Rate is one of the most powerful funding tools available to public schools and libraries in the United States — and right now, it is under fire. In this episode of the IT Directors Podcast, Jay Bradford and Michael Thomas sit down with Dan Rivera, Director of Business Development at Ruckus Networks, to break down everything IT directors need to know about E-Rate. From what it covers and what it does not, to common application mistakes, competitive bidding requirements, the recent FCC vote that has the entire K-12 community on alert, and how to protect your district from costly clawbacks — this episode is the most practical E-Rate conversation you will find anywhere. Whether you are a seasoned IT director who has been through multiple E-Rate cycles or a new technology coordinator trying to figure out where to start, this is the episode that will change the way you think about E-Rate and what is at stake for your students.
Welcome and Introductions
Jay Bradford: Hey, what is going on? This is Michael and Jay, and we are here on the IT Directors Podcast. We have a great guest today. Hello, hello.
Michael Thomas: Oh yeah, Dan, we appreciate you joining us today.
Dan Rivera: It’s my pleasure, Michael. Thank you, Jay. Thank you for having me.
Jay Bradford: Look, we have Dan all the way coming from Ruckus in California here to Birmingham, Alabama — to our studio.
Michael Thomas: Oh yeah, I originally thought, “Hey, we were going to be able to do this with our software and bring you in,” but man, we appreciate you coming here in the flesh.
Dan Rivera: It’s my pleasure to be able to come out face to face with you at Clear Winds Technologies. I wanted to make sure that we were here in person. It’s important for me to be here, so thank you for that.
Jay Bradford: Oh yeah, absolutely. I mean, look, we have had a chance to spend some time with Dan today and just get to know him on a personal level. And look, I think our listeners and viewers are going to love this episode. There is going to be a lot of great information. But I want to take this moment to introduce Dan a little bit. Dan Rivera from Ruckus is the Director of Business Development and Relationships globally for North America for Ruckus. And man, it is just a pleasure to have your knowledge, your wealth of experience, and your background on our show today to talk about E-Rate Under Fire. E-Rate is a huge topic, especially in public education and K-12, which benefits greatly from it. So Dan, just tell us a little bit about yourself and how you got to where you are right now.
Dan Rivera's Background: 37 Years in the Industry
Dan Rivera: Excellent. Thanks, Jay. And it really is appropriate that we’re talking now because of some major announcements and things that we’ll obviously get into later. So I have been in this industry since 1989. I started at a small cabling company doing cabling for mainframe computer systems, making little modular adapters, trunk cables, and octopus cables. So I’ve been in it for just a little while — like 37 years now. I actually got into the networking side of it by selling to a customer. A school had called and asked for a network component. I can’t call it active because it was passive — it was a 10BASE-C hub made by a brand called Asante. So it’s an older brand, not really around much anymore. But we sold this Asante 10BASE-C hub. It was just a dumb hub. We sold it, made the profit from it, and went, “Wow.” In order to make the same amount of profit that we just made by reselling this product, it would take us eight labor hours to do that with cabling. And no one had to crawl under a bungalow in 100-degree weather.
Michael Thomas: Yeah, yeah, yeah.
Dan Rivera: So I said, “Let’s look into this.” So while I was at this small cabling company out in Southern California, we decided to start selling networking equipment specifically to schools, and really grew from there. I ended up doing consulting — business to business consulting for public sector companies that wanted to sell into the public sector. And then I ended up at another manufacturer from 2015 to earlier this year, and then I left that brand to come over to Ruckus. So as of the recording today, this is my 90th day at Ruckus.
Michael Thomas: Congratulations.
Dan Rivera: Thank you. My three-month anniversary.
Michael Thomas: Thanks for sharing that 90-day milestone with us. Yeah. Well, I know we’ve mentioned it before, but we said the word E-Rate. What is that word? I know this is your biscuits and gravy — you’re in Alabama now. So take us into E-Rate. What is it? What does it mean? And what does your role look like within Ruckus?
Dan Rivera's Background: 37 Years in the Industry
Dan Rivera: Excellent. All right. So E-Rate is a funding program. They call it E-Rate — that’s actually short for the education rate, but it’s really just a nickname. So E-Rate is part of the Schools and Libraries Division of the Universal Services Funding Program. Now, the Universal Services Funding Program was started all the way back in 1996 as part of the Telecommunications Act.
Jay Bradford: Was that Bill Clinton with the bill when he was in office?
Dan Rivera: That was Bill Clinton. Yeah, I remember that. He signed that into law. And what’s funny is this was actually a brainchild of Al Gore, Vice President at the time.
Jay Bradford: Okay.
Dan Rivera: And —
Jay Bradford: Hey, he was the self-proclaimed inventor of the internet, by the way.
Dan Rivera: That’s exactly right. And it does tie back to this actual E-Rate program. So they originally called it the Gore Tax when it first came out.
Michael Thomas: Okay.
Dan Rivera: And hence why he said famously — you know. However, it is a great program. It’s more of a subsidy program, so it’s not federal funding. The funding actually comes from all of us who have a landline or a cell phone. If you look on that phone bill, you’ll see a little universal service fee or universal service fund charge — around $4, sometimes less, sometimes more. That generates about 10 to 12 billion dollars a year, which gets split up into four different programs: high cost, low income, rural healthcare, and schools and libraries. Schools and libraries for this last year got about $5 billion, and that is where the E-Rate program comes from. And what’s great about the way that funding is set up — since we all pay into it — it’s not appropriated by Congress.
Jay Bradford: Oh, nice.
Dan Rivera: Mm-hmm. So even though this program has been around since 1996 and the first funding year was in 1998, there have been about 16 or 17 government shutdowns — either partial or full — and none of them have affected the E-Rate program.
Michael Thomas: About 16 or 17. Yeah. That’s just a crazy fact.
Dan Rivera: Right? But none of them have affected the E-Rate program because the funding doesn’t stop. It does not get appropriated by Congress. And that’s a great setup. That was actually challenged at the Supreme Court last year, and the Supreme Court ruled that it was a fully constitutional way of doing it.
Michael Thomas: Okay.
Jay Bradford: Well, I mean, and I love the fact that it’s not a federally funded program, even though our government manages it. But it’s distributed from, like you said, our phone bills, from the tax and from all that. And in that way it’s not constrained by these situations that happen in government, which is really great for our K-12. I was a previous IT director and our district was 89 to 90% E-Rate, and hey, we couldn’t have functioned without E-Rate, Dan. And in a lot of these districts, they can’t function without that funding.
Dan Rivera: Absolutely. And we saw this before the E-Rate program. Way back in the early ’90s, there was an initiative to bring internet into the schools — a nationwide initiative. I believe it was called Internet Day, and they invited parents and community members to come into schools to help run cabling and install networking. And that was not good. You had parents punching holes through firewalls to put cabling in. And so this is where you had some senators, like Senator Markey, step up and say, “Well, we have this Telecommunications Act, and let’s put it in there to where we can provide some subsidies to the schools” — anywhere from 20% all the way up to 90% subsidy — to help bring internet into a classroom or into the public area of a library.
What Does E-Rate Cover? Category One and Category Two Services
Jay Bradford: So Dan, you’ve touched on it a little bit, but give us a high-level overview of what E-Rate covers. Because I was an IT director and we had a person that handled our E-Rate — an E-Rate coordinator — because we were a large district. I just wanted to buy server storage and all this stuff. I’d go to her and say, “Hey, can I E-Rate this?” So for our listeners and viewers, especially in the education space, Dan — what is E-Rateable, and what does it cover for our districts?
Dan Rivera: Well, I will say — with Ruckus, everything Ruckus sells, E-Rate covers. No, I’m kidding.
Michael Thomas: I was about to say.
Dan Rivera: It covers a little bit more than just that. So there are two categories of service. They have what’s called category one — or in the original terms of E-Rate, known as priority one. Category one refers to things that are external to the school campus: things like external connections, your ISP services, and WAN services. And then you have internal connections, or category two, which are things that are on the campus. This includes infrastructure cabling — so cabling, racks, cabinets — as well as UPSs, caching servers, and then of course the networking side of it: wired networking, so switches, as well as access points, firewalls, and then things that go along with the networking, such as controllers, licensing, software subscriptions, and of course support.
Jay Bradford: Yeah, I mean, when I first started out in technology we had T1s. That was the first E-Rate. We put three computers in every classroom, every teacher got a laptop — which was as thick as this coffee mug right here back then. It was a Compaq brand, which is not even around anymore. And then we got a T1, which was 10 meg to each school. That was what our T1 connection was. And then we went to 100 meg and I thought, “Man, we are killing it.” And then when I retired we had 10 gig to every location, but our E-Rate did all that for us.
Dan Rivera: Yes. And that really speaks to the importance of the E-Rate program, not just for schools and libraries, but for the rest of the community. So if you think about it — in the days when you could barely get 10 megabits at home, a T1 would typically average in the ’90s about $3,500 to $5,000 a month.
Jay Bradford: A month, yeah.
Dan Rivera: Right? And your home user was getting 28.8K or maybe 56K over a typical phone line. But when you came out with ADSL or DSL — digital subscriber line — you were spending $40 or $50 a month but only getting about 10 megabits download. Because of E-Rate and the expansion of the networks — the whole Universal Services Funding Program with high cost, as well as the expansion of networks to support communities — you now had the ability at home, I have a gigabit to the house and it’s $100 a month.
Jay Bradford: Yeah.
Dan Rivera: Right? Which is incredible. So E-Rate has really allowed not just schools and libraries, but also the surrounding communities, to have access to the internet at a very affordable price.
Michael Thomas: It has definitely transformed that realm today. I’ll say one thing, working so closely with a lot of schools — I find that it’s not the easiest process at times. If it’s a larger district, they might have someone who is an E-Rate specialist, but some of the smaller ones, or if you have a new IT director, they might not be the most familiar with it or comfortable making those types of decisions. So let’s even talk about mistakes — what are some of the most common mistakes you see people making through this process?
Common E-Rate Mistakes and How to Avoid Them
Dan Rivera: Yeah, that’s a great and fair question. Within the E-Rate program, at the schools you will have E-Rate coordinators. Each state has a state E-Rate coordinator. But often schools — the applicants themselves — will use an E-Rate consultant to help fill out their paperwork and make sure everything is done correctly. And there are different levels of consultant groups, right? If you think about doing your taxes — some people can do their taxes with an online program. There are consultants that offer that type of service. Then there are others who feel more comfortable having a CPA do their taxes. So there are consultants that will come on site, be there, and fill out the paperwork. And then you also have consultants that will provide technical services. All that to say, there is a large mix — I think it was 80% or 84% based on a survey — that applicants will use an E-Rate consultant for their applications. So is it an applicant mistake or a consultant mistake? It depends on each situation. But common mistakes — the biggest thing we see is people failing to identify budgets. Specifically, failing to identify the budget line to pay for their district match. Other very common mistakes that lead to rejection are asking for products that are simply not eligible. The E-Rate program has some rules that say — if you look at your funding request and you have, say, 10 items on there, and out of the total cost less than 30% are deemed ineligible, then they’ll partially fund that application. So you might see them deny 20% of it because of ineligible services or products, but they’ll fund the rest. However, if more than 30% of that application includes ineligible products, they’ll actually deny the whole application outright. So common mistakes include asking for things that are not eligible. We also see some failure to do competitive bidding appropriately. Within the E-Rate program, every applicant is required to go through the competitive bidding process, which includes a Form 470 — that’s kind of their version of an RFP. They have to have that posted for a minimum of 28 days before they select a service provider, engage a contract, and apply for E-Rate funds through a Form 471. A lot of common mistakes within that competitive bidding process happen when applicants say, “Well, I’ve used this vendor, or I’ve used this brand, so I’m just going to spec that brand for my application and not accept any other competitive bids.” Well, that’s actually a violation. There was an order called the Queen of Peace order that the FCC put out a few years ago that said, “You can ask for a specific brand, but you must include the words ‘or equivalent.'”
Jay Bradford: Or equivalent. Mm-hmm. Yeah. We respond to those all the time. And hey, I’ve helped our sales team with that very thing — we want Cisco switches or equivalent, we want Ruckus switches or APs or equivalent. And hey, as a school district, they might want Ruckus, but they’ve got to put “or equivalent” in because of the laws that govern that. I’ve been on both sides — from the vendor and also from the customer perspective on those committees. So I understand what you’re talking about, because that “or equivalent” can really be a game changer. And we’ve actually awarded bids in my previous role to a manufacturer that we didn’t currently have, but their bid was equivalent and it was actually better. So that’s pretty interesting.
Dan Rivera: Yeah. And I would encourage everyone — as you’re going through the process, make sure you do look at equivalent products. And that goes for all networking too. But with all the advances that have been made in the industry, it’s a great time to take a look at all the vendors out there to see what is going to work best for you. It might be a product that is newer to your district or newer to your library.
Jay Bradford: And I think that’s where Ruckus stands out — and Dan doesn’t know this, but Michael and I have talked about this. I’ve been saying it since I’ve been in this role: the partnership and the support that Ruckus offers K-12 is unlike any other manufacturer I’ve seen, and we work with a lot of manufacturers. We love all of our manufacturers — they all have pros and cons — but from a networking perspective, Ruckus has been really great with serviceability and how they communicate. They bring people on site to our K-12 customers, because a lot of these K-12 environments don’t have full IT staff like the larger districts do. It was a teacher who knew how to check email who became the tech coordinator and now is managing the whole network design without knowing all the resources available. So Ruckus is really good at walking them through that. I’ve seen our local Ruckus rep in the state of Alabama, Galen Brazil — big shout-out to Galen if you’re listening to our podcast — and Kyle Wilbur, our channel manager. I’ve seen Galen at these E-Rate bids just helping the customer walk through the process, helping them design and implement things. Because Ruckus sees the benefit of being an asset to the customer. So kudos to you guys for that, to be honest with you.
Dan Rivera: Ah, well, thank you, Jay. That means a lot. And that is part of the reason why I chose to work at Ruckus. I’m very fortunate that I’m at a point in my career where I do get to choose where I work, and that was one of the things that was very attractive to me. Ruckus as a brand — one of our main verticals is K-12 in the United States. It’s a vertical that we focus on. We actually build what we call purpose-driven networks. We build the product with that use case in mind, specifically for K-12. And K-12 is my favorite industry — I’m not just saying that. I actually had the privilege of sitting on a school board for two and a half terms until I termed out, and I was on their tech committee. So K-12 has just been a big passion of mine really since the early 2000s when I started getting heavily involved in ed tech. I love the K-12 industry. And I’m really proud to be able to work for Ruckus, which truly has a great focus on this. So thank you. And that is something we can do even within the terms of the program — we can engage with any of the applicants as long as we’re not trying to influence or lock out any kind of sole source situation.
Jay Bradford: Provide information and help guide them through, you know?
Dan Rivera: Yes. And we’re not trying to sole-source anything. Everything is going to be above board. One thing I have always said — in my personal life, I will never do anything illegal, unethical, or immoral. And that includes my professional life as well. And it’s great to be part of an organization that feels the same way.
Michael Thomas: Yeah. It goes a long way. I think at the end of the day, we’re talking about this topic because it’s really about serving with integrity. So hey, we are like-minded, and I can appreciate that perspective.
Jay Bradford: Absolutely. Yes. You know, Michael, what about the new FCC ruling that just came down last week?
E-Rate Under Fire: The FCC Vote and What It Means for K-12
Michael Thomas: So from where you sit working with school districts every day, how seriously should IT directors be taking this?
Dan Rivera: Okay. So a little bit of context. There was a recent vote by the FCC. They had put forward what’s called a notice of proposed rulemaking and a further notice of proposed rulemaking. They actually took a vote on it last week. For terms of the podcast, I think the official date was June 24th or June 25th. And it basically asks several questions. One big one that people should be concerned with is: is the E-Rate program worth keeping?
Michael Thomas: Yeah.
Dan Rivera: Yes. Oh man. Yes, it is. Because as you would say, Jay — how critical was the E-Rate program to your district? And even one step further — how important is it to the kids?
Jay Bradford: Absolutely.
Dan Rivera: Right? When we look at 21st century collaborative learning, everything relies on access to the internet.
Jay Bradford: Yeah, connectivity.
Dan Rivera: Yeah. And so for the one answer — is it important? Yes. Yes, it is important. There are several other questions that they put forward as well — things about competitive bidding, things about a service provider’s role versus a consultant’s role. So the FCC Commission did approve this NPRM and further notice of proposed rulemaking, or FNPRM. And what that means is that now we as a community — and I say we, meaning applicants, whether you’re a library, whether you’re a school, IT administrators, superintendents, librarians, or E-Rate consultants — it is our time to let the FCC know: yes, it is important. You can see on the FCC’s website at fcc.gov, under the Wireline Competition Bureau tab, you’ll be able to see the NPRM and the FNPRM. Additional context will come out as the Wireline Competition Bureau releases a lot of these questions. But it is important for you as a stakeholder in the E-Rate program — whether you’re a partner, a service provider, a brand, or an applicant — to let your voice be known and answer these questions. And one shout-out to Joy Wendler and the crew at the Shelby organization — they created a website called Save Our E-Rate at saveourerate.com. From there you’ll be able to see some resources, whether you’re a K-12 school in partnership with CoSN, which put together some great information on how you can get involved, or if you’re a superintendent with the Superintendents Association, or a librarian with the Association of Libraries. Each one of these has great information on how stakeholders can get involved and respond to the FCC. It is important, because one thing I have learned having been part of the E-Rate program since the beginning — the FCC does listen. So it is critical that you as an applicant submit that information. Because we can do it as a brand, but they look at us and say, “Well, you have a financial motive.”
Michael Thomas: Yeah. Well, and I think we can even put a link to that in our show notes. I think that would be beneficial as well.
Jay Bradford: Oh yeah. We’ll do that for all of our listeners and viewers. And man, it is scary to me, Dan, to be honest with you, that the FCC could even bring this to the table. Because here’s the reality — I don’t know, probably 5% of school districts across the United States of America could afford their connectivity on their own. And I might be stretching that. This is just Jay data — I haven’t vetted this — but I’ve been in the education space for 25 years, and now I’m consulting with Clear Winds. I run into a lot of school districts. I would say the ones I’ve come into contact with since my retirement, it might be less than 3% that could actually afford their fiber connection, their connections to the internet. Like in Alabama, we have Alabama Supercomputer, which is an authority that gives every school free internet up to 100 meg. After that, you have to pay for it. And who can operate on 100 meg in today’s world? Even if you’re a three-school district, maybe. But I don’t know how the FCC even thinks that’s a reality for these districts to function. I mean, they might have $2 million in E-Rate funding, and all of a sudden they have to make up $2 million on their own. The rural communities, some of the urban school districts that don’t have the tax base — I think it’s a very serious issue that we all need to advocate for in our education environment. Because man, without E-Rate, these school districts cannot function in teaching and learning. Because everything in teaching and learning now is tied to one-to-one devices, Chromebooks, Schoology, LMSs, and all these things. I didn’t even know about this FCC development, Michael, until our great marketing team gave us that information, and when Dan wanted to be on the show. And I thought that’s incredible — it just blows my mind that they would even bring this up. Because you can’t just give money one time and then never sustain that connectivity. It would be like, “Hey, Alabama Power is going to give you a free power bill for 10 years, but after that we’re not doing it anymore.” Well, how do they pay for the power bill?
Dan Rivera: Right. Just because the infrastructure is there doesn’t mean that the service being charged for is going to still be affordable.
Michael Thomas: We’ve built a system that relies on it, and they’re now trying to pull something out from under it. What do you expect?
Dan Rivera: Yeah. I will say the FCC isn’t necessarily the bad guy here. Chairman Carr has put together some valid questions. Like, are there services that we could no longer provide? He’s also within this order asking are there other services that we need to look at expanding? Is there a way to simplify CIPA — the Children’s Internet Protection Act — for example? Should we look at including network security as an eligible service? So there are some good aspects to this too. And then there are commissioners on the FCC — Commissioner Gomez actually put it out. She dissented in part. She approved overall, but dissented in part. And part of her testimony or notes on her vote was: even the Department of Education has stressed the importance of teaching AI in schools — and how are we going to be able to teach students how to use it without connectivity?
Jay Bradford: Without connectivity.
Dan Rivera: Without connectivity. So it is something that — personally, having been involved in the program for this long — I don’t think the program overall is in jeopardy. I do think that there are changes that could be bad if we don’t have enough applicants making their voices heard with the FCC to say, “No. Keep these services. Here’s why this is important. Here’s the success that we’ve had.” So while I don’t think the program overall is in jeopardy, I do think that if E-Rate has been important to you — which it has been important to over 90% of the schools in the United States — let your voice be heard.
Jay Bradford: Yeah, I mean, I don’t really know a district that hasn’t benefited from E-Rate in the public sector when it comes to connectivity. I mean, that’s how they all have internet connectivity — and the switching, routing, controls, APs, and everything in the background. So I think it’s really advantageous for all of our listeners and viewers to be engaged with this. And each state has a technology organization — like here in Alabama we have ALET and AETC, in Tennessee they have TETC. So I would urge all of our listeners and viewers in all the states we serve to really be engaged with your technology organization and rely on guys like Dan and some other providers to give you some guidance and direction around that.
How to Navigate the E-Rate Application Process
Jay Bradford: That kind of leads into our next question, wrapping up, Dan. Like, as an IT director in school district X, if I’ve had some bad experiences with E-Rate — some stuff not covered, tough to navigate — what advice would you give to our IT directors and CTOs throughout all of our K-12 environments on how to navigate filing for E-Rate?
Dan Rivera: So I would say a couple of different ways to look at it. If you were to go with a consultant, go with a known consultant. There are national groups that have created a professional organization for E-Rate managers. There’s a group called EMPA — the E-Rate Management Professional Association.
Jay Bradford: Have you ever heard of Funds for Learning?
Dan Rivera: I’ve heard of Funds for Learning — who is also a founding member of EMPA. John Harrington over there.
Jay Bradford: Yes. So I worked closely with Funds for Learning. I’ve never shared this with our team, but I was really close with them. Because we did millions of dollars of E-Rate in my previous district — we were heavily free and reduced lunch and had a lot of E-Rate. But Funds for Learning was great. We used them because without them, we wouldn’t have been able to function. We had an amazing E-Rate coordinator in the school district I came from. She is brilliant, but we relied on Funds for Learning a lot. So anyway, go ahead. I just wanted to mention that.
Dan Rivera: No, and going back to what we said earlier — there are different levels of service that every consultant will offer. There are some E-Rate consultants that will say, “Look, we’ll just take care of everything for you” — not just filing, but also what’s called a PIA, or program integrity assurance review. Every application for E-Rate goes through this PIA where a reviewer at USAC says, “Is the paperwork filed correctly? Are the services eligible?” And many times there will be questions that reviewer has for the applicant. So they’ll send questions, and how you answer those are just as important as the original filing. There are consultants that can walk you through all of that. There are also consultants who have developed systems online to help you fill it out yourself. But it is important to go with a reputable consulting firm. And if you’re going after a lot of big dollars, just don’t go after it alone. Connect with someone to make sure your numbers are correct. As a brand or as a partner, there are limited things we can do to help fill out any forms — we can’t do that. However, on the back end, once you’ve gone through your competitive bidding process, we can actually help you answer some of these PIA questions once you’ve signed a contract and gone through the competitive bid process. Before you even get there, before you file a Form 470 as an applicant, a best practice is to consider other networks. Look at what’s out there and what’s going to be best for you — whether it’s a UPS, cable infrastructure, or network infrastructure. Don’t be afraid to go out and talk to those brands and say, “Hey, let’s talk about what is in the industry today.” Because if the last time you upgraded or refreshed your network was in 2020, there have been a lot of innovative changes since then. And you might say, “Okay, well, is Wi-Fi 7 really important for me and for my district?” Well, talk to us. Talk to other brands and say, “Okay, what is the benefit of using Wi-Fi 7 in my network?” Because schools have more devices than ever — whether they’re school-owned devices or student devices or other products. We talked a little bit about video cameras, security cameras — IP enabled, right? They go across the network. You look at all the access control systems — those go across the network now. Pretty much everything, whether it’s digital screens, PA announcement systems, AV systems — all of it is going across the network. And primary connections for a lot of things are becoming wireless. So it’s a matter of figuring out what the real need is within your school system. As an applicant, I would look to the different brands and say, “Okay, let’s talk about how your product would impact our network and what advantages we have, and what technologies we should be looking at.”
Michael Thomas: We can get so stuck into doing the same thing because it’s what we’ve done before. But I think if you have an open mind and approach it with an open mind, you will be surprised. There are likely better things out there or options that can better meet your needs today. And I think that’s one of the big things.
Jay Bradford: Reset E-Rate as an opportunity to really advance your technology and change the landscape of your environment. Hey, you only get it once in a while, right? So use that.
Dan Rivera: Yeah. Use that. Once every five years.
Jay Bradford: Once every five years. Those cycles come through. And I was in five iterations of E-Rate over my career, and man, we made some drastic changes — from T1 to 10 gig to APs, to all kinds of things. And it was so fun to see that evolution happen. And you touched on something too — you talked about USAC and documentation. I think that’s something that a lot of districts miss when it comes to E-Rate: documenting the assets and all these kinds of things. We have a tool at Clear Winds, School Manager, that not only is your asset tracking manager, but also allows us to track software. And our development team designed it really around E-Rate tracking — the licensing and documentation. Because when USAC calls and wants documentation, you’ve got to be able to provide it. If you can’t, then we’ve got a funding issue. And our owner and our team kind of looked down the runway and saw that coming. I think that’s another great tool for people to use. You’ve just got to track these things around E-Rate.
Dan Rivera: Yeah. And if I can add to that — this is why it’s so important to choose not just the right brand, but the right service provider within the E-Rate program. Because not only do you have applicants receive the worst thing you can get — which is called a COMAD, a commitment adjustment — that means you’ve already done the project, it’s long gone, you’ve paid your match, and then USAC comes back and says, “Oh, by the way, that project that we just gave you $850,000 for two years ago — that was not right. We need that money back. We’re adjusting that commitment.” And that’s the worst thing you could do, and we see it every year. We see the FCC going back through appeals and clawing back millions and millions of dollars. There was one appeal where USAC had made the determination that six years ago, an applicant received funding they should not have received. They appealed it to the FCC, and it took a few years, but the FCC actually came back and said, “Yeah, you need to pay that money back.” And part of the issue was they couldn’t identify whether a particular switch was purchased in 2018 or 2019 — which year was it bought? So tracking is so important.
Jay Bradford: Hey look, I lived it, Dan. I’ve been there. In all of my E-Rate iterations we never had that happen, but we had on-site evaluations, end questionnaires, and documentation requests. I mean, when you’re getting a couple million dollars, they’re not just going to take your word for it. We had a phenomenal E-Rate coordinator in my previous district, but we also worked with a great partner. We were always able to provide what was requested. And man, she was a stickler. I can remember being in meetings like, “We’ve got to have that labeled, we’ve got to have the switch tagged.” We had federal tags, E-Rate tags, asset tags — but we needed to know where everything was that we bought with E-Rate, how we allocated it, and when. That’s really big. But if you don’t have the trusted partner or someone telling you that, you really don’t know. And I think that’s where people kind of shy away. Some of the districts that don’t have those resources are like, “Man, I just can’t do that.” But then they lose the benefit of all the gain for the students in teaching and learning — because that’s what it’s for.
Dan Rivera: Yeah. And you mentioned the great things that Clear Winds is doing, which is important — knowing where that product is, and making sure it’s still being used in an eligible way.
What Is and Is Not E-Rateable: Common Misconceptions
Jay Bradford: Yes. So we had a scenario — and it’s hard for me because I know so many districts and have been so ingrained in this — but there was a local district where someone tried to E-Rate their jumbotron. You know, even though a jumbotron is connected to the Wi-Fi or might be wired in — hey, I mean, I knew districts and folks who tried. The school boards, the — I mean, clearly that is not E-Rateable, but you just have to know.
Dan Rivera: Yes. And not only that — here’s why it works the way it does. The FCC doesn’t release an eligible products list. They release an eligible services list. And the reason being is you might have a switch. A switch is not an eligible service. Yeah. Therefore, that switch is not eligible.
Jay Bradford: Right. So I used to argue with our E-Rate coordinator all the time. “Look, the switch is providing a service.” And she’d say, “Jay, it’s not serving the kids, it’s not eligible.” Like, “But we’re supporting teachers.” “Well, can you not get them to do it?” Yeah. So look, I’ve been on both sides of it. I tried to push the envelope a little bit. You’ve got to read the lines and the fine print. But we had a great partner that helped us navigate all that. And hey, you just don’t know what you don’t know. You think just because something is connected, “Oh, it’s E-Rateable” — and that’s just not the case. So it’s funny you mention that about the services. We went over a whole thing at our Alabama Technology Association last fall about the eligible services list, because jumbotrons and things like that are becoming very common in high schools, especially in the South. Every stadium wants a big jumbotron. So people are saying, “Hey, I can’t spend half a million dollars on this thing. Let’s try to E-Rate it.” But E-Rate is clear that it’s not E-Rateable. People were trying because they just didn’t know.
Dan Rivera: And when you work with a solid provider, they can inform you as an applicant and say, “Look, this is not E-Rate eligible.” So you can have those conversations with your service providers. And I’d encourage all of you as applicants to connect with your service providers. You can connect with me — and whether you are a Ruckus customer or not, I am happy to give you some guidance and support. Because the reality is I’ve been in this program a long time. I am heavily invested in the success of the program because I believe in it. I’ve seen what it did for the district that I was fortunate enough to serve on the school board for, and I’ve seen what it has done for our customers and for our community overall.
Closing Thoughts
Jay Bradford: Man, well, Michael, this has been an awesome episode.
Michael Thomas: No, it has, definitely.
Jay Bradford: I think our listeners and viewers — look, if you’re an IT director in K-12 in particular — really go back and listen to this. Go follow us on all the social media platforms. Listen to this episode with Dan, because I think the information he has given is really valuable. And just the wealth of knowledge and the resources that you offer — and hey, anything good, they’re going to try to do whatever to it. But I think with the community voice, and how much E-Rate is sustainable and how much it supports our students, we have to keep it around. Because it’s all about teaching and learning in our districts. So hey, Dan, thank you so much. And thanks for coming out in person to be with us in the studio today. We really appreciate it so much.
Dan Rivera: Oh, it’s my pleasure, Jay. Thank you so much for the invite. Thank you, Michael. I am really happy to be here, so thank you so much.
Jay Bradford: Awesome. We are glad, man. Well, this is Jay and Michael. We are signing off on the IT Directors Podcast. Thank you.
E-Rate Is Worth Fighting For: Here Is What You Need to Do Next
E-Rate has been the backbone of K-12 connectivity in the United States since 1998, and for the vast majority of school districts across the country, it is not optional — it is the only reason they have internet access at all. As Dan Rivera makes clear in this episode, the program is not going away, but changes are coming, and the districts that stay silent during the FCC comment period are the ones most at risk of losing the services they depend on. If E-Rate matters to your district, go to saveourerate.com, make your voice heard with the FCC, work with a reputable E-Rate consultant, document every asset you purchase with E-Rate funds, and do not wait until the next funding cycle to get organized. And if you are not sure where to start, Clear Winds is here to help — from asset tracking and documentation to understanding what is and is not E-Rateable in your environment, our team works alongside K-12 districts every day to make sure they are getting the most out of their E-Rate funding. Reach out to us at clearwinds.net to start that conversation. For more episodes on E-Rate, K-12 technology, and IT leadership, subscribe to the IT Directors Podcast on Spotify, LinkedIn, and Instagram, and visit clearwinds.net for show notes, resources, and links mentioned in this episode.
